Controlled foreign corporation rules – Part 3

Select jurisdictions CFC rules

CFC legislation is adopted in many countries although with some differences. It is important to analyse the practices followed by different state and to understand the similarities and differences in measures opted by different countries.

CFC rules were first introduced as ‘Subpart F’ legislation in the United States in 1964. Germany followed in 1972 using the US rules as a blue print. In 2013, more than 30 countries worldwide used CFC rules to limit profit shifting by multinational corporations[1] . The number of countries introducing CFC rules has been growing since then.

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